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insurance plan. However, petitioner did not directly pay any
other expenses for the children on a routine basis.
During the year in issue, Ms. White lived in a three-bedroom
apartment with the four children. She was employed part time as
an assisted living care provider, and she received approximately
$1,500 per month in welfare and Social Security income. The
children were covered by a State medical insurance program. Ms.
White estimated her monthly expenses during that year to be as
follows: $575 for rent, $100 for utilities, $40 for life
insurance, $45 for telephone service, $300 for food, and $280 for
a car payment and car insurance. Because two of petitioner’s and
Ms. White’s children are developmentally disabled, Ms. White must
incur additional expenses.
The first issue for decision is whether petitioner is
entitled to four dependency exemption deductions. Petitioner
claimed dependency exemption deductions for Tristan, Harvey,
Khyrie, and Kares. Respondent disallowed each of these
deductions.
Among other requirements, a taxpayer generally is entitled
to a dependency exemption deduction for a child only if the
taxpayer provides over half of the child’s total support during
the taxable year. Secs. 151(a), (c) and 152(a). The total
support for a child includes the entire amount of support which
the child receives from all sources, including Social Security
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Last modified: May 25, 2011